Ghana has secured a major victory in its tax dispute with Tullow Ghana Limited after an International Chamber of Commerce (ICC) Tribunal dismissed the oil producer’s claims and upheld a US$393.09 million tax assessment by the Ghana Revenue Authority (GRA).
The Tribunal delivered its decision on Tuesday, September 29, 2026, following arbitration proceedings conducted under the ICC Rules of Arbitration.
The dispute centred on the tax treatment of business interruption insurance proceeds received by Tullow.
In its ruling, the Tribunal upheld in full the GRA’s assessment of US$393,091,993.70, rejecting Tullow’s claims against the assessment.
It also ruled that the assessment did not breach the applicable Petroleum Agreements, while confirming that the penalty imposed by the GRA was properly applied.
The Tribunal further rejected Tullow’s argument that the assessment was time-barred and found that the GRA’s enforcement action was lawful.
The ruling represents a significant development in the long-running tax dispute between the Ghanaian government and Tullow, one of the country’s major petroleum producers.
According to Finance Minister Dr Cassiel Ato Forson, government will now take steps to implement the award in accordance with Ghanaian law.
Dr Ato Forson commended the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for defending Ghana’s position throughout the arbitration.
He said the outcome reinforces government’s position that all companies operating in Ghana are subject to the country’s laws.
“This outcome vindicates the position Ghana has maintained throughout: that every company operating in this country, regardless of its size, is subject to the laws of Ghana,” Dr Ato Forson said.
The Finance Minister said the ruling confirms the validity of the GRA’s assessment and its authority to enforce tax obligations arising from activities carried out in Ghana.
Despite the favourable outcome, however, government says it remains committed to resolving outstanding tax matters with Tullow amicably.
Dr Ato Forson disclosed that discussions between the government and Tullow were already underway before the Tribunal delivered its award.
